The transfer of assets of a private foundation to another private foundation in a liquidation, merger, recapitalization, redemption, or other adjustment, organization, or reorganization is a section 507(b)(2) transfer. A transfer under this section will not cause the transferee to be treated as a newly created organization for purposes of the private foundation provisions, requiring notice to the IRS to rebut the presumption of private foundation classification. However, the transferee may be required to reapply for exemption if it wishes to be exempt under section 501(c)(3) of the Code.